Every major compliance framework — SOC 2 (CC7.3–CC7.5), ISO 27001 (A.5.24–A.5.28), HIPAA (§164.308(a)(6)), GDPR (Articles 33–34), and PCI DSS (Requirement 12.10) — requires a documented and tested Incident Response (IR) Plan. Auditors do not just check that the plan exists; they verify that it has been tested, that staff know their roles, and that past incidents were handled according to the process.
IR Plan Structure
Phase 1: Preparation
- Define the IR team: Incident Commander, technical lead, legal/privacy counsel, communications lead, executive sponsor.
- Maintain an up-to-date contact list (including out-of-hours contacts) for all IR team members and key vendors.
- Deploy logging, alerting, and SIEM tooling before an incident occurs.
- Establish a secure out-of-band communication channel (IR team members should not assume email is secure during an incident).
- Run tabletop exercises at least annually to test team readiness.
Phase 2: Detection and Analysis
- Classify alerts into incident severity levels (P1–P4 or Critical/High/Medium/Low) with defined response SLAs.
- Log incident details immediately: timestamp, detection source, initial scope assessment, affected systems.
- Determine whether the incident involves personal data — if so, trigger the privacy breach assessment process (72-hour GDPR clock starts when you become "aware").
- Assign an Incident Ticket in your ITSM or incident log. Every action taken should be timestamped and recorded.
Phase 3: Containment
- Short-term containment: Isolate affected systems (network segment, disable accounts, block IP ranges) without destroying forensic evidence.
- Long-term containment: Apply temporary fixes to allow business to continue while full remediation is prepared.
- Preserve forensic evidence: memory dumps, log exports, disk images where appropriate.
Phase 4: Eradication
- Identify root cause: vulnerability exploited, phishing credential compromise, misconfiguration.
- Remove malware, close attack vectors, revoke compromised credentials.
- Apply patches and update firewall rules/WAF signatures.
- Verify eradication with a security scan before proceeding to recovery.
Phase 5: Recovery
- Restore systems from clean backups, or rebuild from infrastructure-as-code where available.
- Reintroduce systems to production in a controlled, monitored manner.
- Monitor closely for 24–72 hours post-recovery for signs of re-compromise.
- Notify affected customers, partners, or regulators as required by law (GDPR: 72 hours; HIPAA Breach Rule: 60 days; US state laws vary).
Phase 6: Lessons Learned
- Hold a post-incident review within 2 weeks of closure.
- Document root cause, timeline, actions taken, and recommendations.
- Update the IR plan, runbooks, and detection rules based on findings.
- Report findings to executive leadership and, where required, the board.
Evidence for Auditors
- Signed and dated IR Plan document.
- Tabletop exercise records (date, attendees, scenario, outcomes).
- Incident register showing all incidents, severity, response actions, and closure dates.
- Post-incident review reports for significant incidents during the audit period.
- Notification records for any breaches reported to regulators or data subjects.